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Kitchen deep cleaning - allergen labelling law
Natasha's Law changed the rules for food prepacked for direct sale (PPDS). Since October 2021, PPDS food must be labelled with the name of the food and a full ingredients list, with the 14 regulated allergens emphasised within it. Knowing whether your food is PPDS, and labelling it correctly, is a legal duty. Here is Natasha's Law and PPDS labelling duties. This is general information, not legal advice.
The short answer
Natasha's Law is the common name for the allergen-labelling requirement for food prepacked for direct sale (PPDS), which came into force on 1 October 2021 in England, Wales and Northern Ireland. It was introduced following the death of Natasha Ednan-Laperouse, who died from an allergic reaction to a baguette that was prepacked for direct sale and did not carry allergen information on its label - so the law closed a gap in allergen labelling for such food. What PPDS is: prepacked for direct sale food is food that is packaged on the same premises from which it is sold, and is packed before the customer orders or selects it (so it is already in its packaging, ready to sell, when the customer chooses it - as opposed to food packed to the customer's order, or food sold loose/non-prepacked, or food prepacked elsewhere). Typical examples include things like sandwiches, salads, cakes or other items a business makes and packs on site and puts out for sale ready-packaged. The distinction matters because the labelling duty applies specifically to PPDS food. The duty: PPDS food must be labelled with the name of the food and a full ingredients list, with the allergenic ingredients (the 14 regulated allergens) emphasised within that ingredients list (for example in bold, italics, or a different colour, so they stand out). So a PPDS item needs a label giving its name and its full list of ingredients, with any of the 14 allergens it contains emphasised in the list - so a customer (importantly, an allergic customer) can see the full ingredients and identify the allergens. This is a fuller requirement than the general allergen-information duty for non-prepacked food (where allergen information must be available but not necessarily as a full ingredients label on the pack) - PPDS food specifically needs the full ingredients list with emphasised allergens on the label. So the PPDS labelling duties under Natasha's Law are: determine whether your food is PPDS (packed on site, before the customer orders), and if it is, label it with the name of the food and a full ingredients list with the 14 allergens emphasised. This requires knowing the full ingredients and allergens of the food (accurate ingredient and allergen information), so the labelling must be based on accurate knowledge of what is in each product. This is general information, not legal advice; follow the current FSA/GOV.UK guidance on PPDS and Natasha's Law, which sets out the requirements and how to comply.
Key points
What Natasha's Law is
Natasha's Law is the common name for the allergen-labelling requirement for food that is prepacked for direct sale (PPDS), which came into force on 1 October 2021 in England, Wales and Northern Ireland. It requires PPDS food to carry full ingredient labelling with allergens emphasised (covered in detail below), closing a previous gap in the rules. The law is named after, and was introduced following, the death of Natasha Ednan-Laperouse, a teenager who died from an allergic reaction to a baguette bought from a food outlet - a baguette that was prepacked for direct sale and did not carry allergen information on its label. Under the rules that then applied, such PPDS food did not have to carry the full ingredient/allergen labelling, so the allergen (which she was allergic to) was not labelled - and the resulting tragedy led to the change in the law to require PPDS food to carry the name and full ingredients list with allergens emphasised.
So Natasha's Law exists to ensure that food prepacked for direct sale carries clear allergen information on its label - so that consumers, especially those with allergies, can see the ingredients and identify allergens before eating, and such a tragedy is less likely to recur. It is a significant food-labelling requirement for food businesses that make and pack food on site for sale. The key things a food business needs to understand are: whether its food is PPDS (the definition, covered next), and what the labelling duty is for PPDS food (the name, full ingredients list, and emphasised allergens, covered after). Understanding what Natasha's Law is - the PPDS allergen-labelling requirement, in force since October 2021, introduced after Natasha Ednan-Laperouse's death - frames the duties it imposes. So Natasha's Law is the allergen-labelling law for PPDS food, and food businesses need to know whether and how it applies to them. This is general information, not legal advice; follow the current FSA/GOV.UK guidance.
What PPDS is
Understanding the labelling duty requires understanding what prepacked for direct sale (PPDS) food is - because the duty applies specifically to PPDS food, so a business must know whether its food is PPDS. PPDS food is, broadly, food that is packaged on the same premises from which it is sold, and is packed before the customer orders or selects it. So two things characterise PPDS: it is packed on the same premises where it is sold (the business makes/packs it on site and sells it there), and it is already in its packaging before the customer chooses it (it is packed and put out ready for sale, so the customer selects an item that is already packaged, rather than the food being packed to their order). Typical examples include items a business makes and packs on site and puts out for sale ready-wrapped - such as sandwiches, filled rolls, salads, cakes, or similar packaged items on display for customers to pick up.
The PPDS definition matters because it distinguishes PPDS food (which needs the full labelling) from other categories that have different rules: food packed to the customer's order (made and packed when the customer orders it, not prepacked ready) is not PPDS; food sold loose or non-prepacked (not in packaging - like a dish served on a plate, or loose items) is non-prepacked food (with its own allergen-information rules, not the PPDS labelling); and food prepacked elsewhere (packed by a manufacturer off-site, like packaged goods from a supplier) is prepacked food under the general packaged-food labelling rules, not PPDS. So a business needs to identify which of its food is PPDS - packed on site, before the customer orders - because that food carries the Natasha's Law labelling duty. Getting this right (knowing what is and is not PPDS) is the first part of complying - you have to know which food the duty applies to. So understand what PPDS is (packed on the same premises where sold, before the customer orders/selects it) and identify your PPDS food, as the basis for applying the labelling duty. The FSA/GOV.UK guidance helps determine whether specific food is PPDS. So know what PPDS is, and which of your food it covers. This is general information; check the current guidance for the precise definition and examples.
The labelling duty
For food that is PPDS, the labelling duty under Natasha's Law is clear: it must be labelled with the name of the food and a full ingredients list, with the 14 regulated allergens emphasised within that list. So a PPDS item needs a label that gives two things. The name of the food: the name of the product, so the customer knows what it is. And a full ingredients list: a complete list of the ingredients in the food (all the ingredients, as in the ingredients list on packaged food) - so the customer can see everything that is in it. Within that full ingredients list, the allergenic ingredients (any of the 14 regulated allergens present) must be emphasised - made to stand out from the rest of the list, for example in bold, italics, or a different colour - so that the allergens are clearly identifiable within the ingredients. So the label gives the name and the full ingredients, with the allergens highlighted in the ingredients list.
This full-ingredients-with-emphasised-allergens labelling is the specific requirement for PPDS food, and it is fuller than the allergen-information duty for non-prepacked food. For non-prepacked food (food sold loose, not in a package - like a plated dish), allergen information must be provided/available to the customer (for the 14 allergens), but not necessarily as a full ingredients label on a pack (it can be given in other ways, such as on a menu, signage, or orally, as long as it is available). PPDS food, by contrast, must carry the full ingredients list with emphasised allergens on the label itself - a fuller, on-pack requirement. So the PPDS duty is specifically the name plus full emphasised-allergen ingredients list on the label. The purpose is that a customer, especially an allergic one, can pick up the packaged PPDS item and see, on its label, the full ingredients and the emphasised allergens - so they can make a safe, informed choice (which is exactly what was missing in the case that led to the law). So label PPDS food with the name of the food and a full ingredients list with the 14 allergens emphasised. This is the core labelling duty. So the duty is name, full ingredients, and emphasised allergens on the PPDS label. This is general information; follow the current FSA/GOV.UK guidance on how to label PPDS food.
Getting it right
Complying with the PPDS labelling duty requires accurate knowledge of what is in each product - because the label must give the full, correct ingredients and allergens, which the business must know. To label a PPDS item correctly, the business has to know the full ingredients of the product (every ingredient, to list them all) and which of the 14 allergens it contains (to emphasise them correctly) - which means having accurate ingredient and allergen information for each product it makes and packs. This requires good practice behind the labelling: knowing the recipes and ingredients of each product, knowing the allergens in each ingredient (including in compound ingredients and any supplier ingredients used), and keeping this information accurate and up to date (so the labels are correct, and updated if a recipe or ingredient changes). So accurate labelling rests on the business genuinely knowing its products' ingredients and allergens.
Getting this right matters greatly because the labelling is for allergic consumers' safety - an inaccurate label (missing an ingredient or allergen, or a wrong allergen) could be dangerous (an allergic customer relying on it could be harmed), and it is a legal requirement. So the labelling must be accurate, based on genuine knowledge of the food. This means a business making PPDS food needs the systems to know its ingredients and allergens accurately and to produce correct labels - part of good allergen management generally. So the practical duty is: identify your PPDS food, know its full ingredients and allergens accurately, and label each PPDS item with the name and full emphasised-allergen ingredients list - correctly and kept up to date. This connects to the wider allergen management every food business must do (knowing and managing the allergens in its food, and informing customers) - PPDS labelling being the specific labelling application of that for PPDS food. So get the PPDS labelling right through accurate knowledge of your food and correct, up-to-date labels. So complying rests on knowing your food and labelling it accurately. This is general information, not legal advice; follow the current FSA/GOV.UK guidance and ensure your allergen and ingredient information is accurate.
Part of allergen management
So Natasha's Law imposes PPDS labelling duties: food that is prepacked for direct sale (packed on the same premises where it is sold, before the customer orders or selects it) must be labelled with the name of the food and a full ingredients list, with the 14 regulated allergens emphasised within it - a requirement in force since 1 October 2021 (England, Wales and Northern Ireland), introduced after Natasha Ednan-Laperouse's death to ensure such food carries clear allergen information. So a business making and packing food on site must know whether its food is PPDS, and if so, label it correctly with the name and full emphasised-allergen ingredients list, based on accurate knowledge of its products. So determine your PPDS food and label it correctly - the core duty.
PPDS labelling is one part of the wider allergen management a food business must do, which connects to keeping a clean kitchen. Allergen management overall involves knowing and managing the allergens in your food, informing customers (through PPDS labelling for PPDS food, and allergen information for non-prepacked food), and controlling allergen cross-contamination in the kitchen (so allergens do not unintentionally get into foods). PPDS labelling addresses the informing part for PPDS food (the label), while cross-contamination control addresses keeping allergens out of foods where they should not be - and that control depends partly on cleaning (clean surfaces, equipment and utensils, so allergen residues do not transfer between foods). So while PPDS labelling is about the label, the wider allergen management it belongs to also involves cleaning to control cross-contamination. This is where cleaning connects to allergen management: keeping the kitchen and equipment clean supports allergen cross-contamination control, complementing the labelling duties. So comply with the PPDS labelling duties (the label), as part of good overall allergen management - which also includes controlling allergen cross-contamination, supported by a clean kitchen. So Natasha's Law labelling is one part of allergen management, alongside cross-contamination control on a clean kitchen. This is general information, not legal advice; follow the current FSA/GOV.UK guidance on PPDS labelling and allergen management.
Questions
Natasha's Law is the common name for the allergen-labelling requirement for food prepacked for direct sale (PPDS), which came into force on 1 October 2021 in England, Wales and Northern Ireland. It requires PPDS food to be labelled with the name of the food and a full ingredients list, with the 14 regulated allergens emphasised within that list. It is named after, and was introduced following, the death of Natasha Ednan-Laperouse, a teenager who died from an allergic reaction to a baguette that was prepacked for direct sale and did not carry allergen information on its label - under the rules that then applied, such PPDS food did not have to carry full ingredient/allergen labelling, so the allergen was not labelled. The resulting tragedy led to the law requiring PPDS food to carry the name and full ingredients list with allergens emphasised. So Natasha's Law exists to ensure food prepacked for direct sale carries clear allergen information on its label, so consumers (especially those with allergies) can see the ingredients and identify allergens before eating. It is a significant labelling requirement for businesses that make and pack food on site for sale. This is general information, not legal advice; follow the current FSA/GOV.UK guidance.
PPDS food is, broadly, food that is packaged on the same premises from which it is sold, and is packed before the customer orders or selects it. So two things characterise it: it is packed on the same premises where it is sold (the business makes or packs it on site and sells it there), and it is already in its packaging before the customer chooses it (packed and put out ready for sale, so the customer selects an item that is already packaged, rather than the food being packed to their order). Typical examples include items a business makes and packs on site and puts out ready-wrapped - sandwiches, filled rolls, salads, cakes, or similar packaged items on display for customers to pick up. The definition matters because the Natasha's Law labelling duty applies specifically to PPDS food, distinguishing it from: food packed to the customer's order (not PPDS); food sold loose or non-prepacked (with its own allergen-information rules); and food prepacked elsewhere by a manufacturer (under the general packaged-food rules). So a business must identify which of its food is PPDS - packed on site, before the customer orders - as that food carries the PPDS labelling duty. Check the current FSA/GOV.UK guidance for the precise definition and examples. This is general information.
The name of the food and a full ingredients list, with the 14 regulated allergens emphasised within that list. So a PPDS item needs a label giving: the name of the food (so the customer knows what it is); and a full ingredients list (a complete list of all the ingredients, as on packaged food, so the customer can see everything in it). Within that full ingredients list, the allergenic ingredients (any of the 14 regulated allergens present) must be emphasised - made to stand out from the rest, for example in bold, italics, or a different colour - so the allergens are clearly identifiable. So the label gives the name and full ingredients, with the allergens highlighted in the ingredients list. This is fuller than the allergen-information duty for non-prepacked food (where allergen information must be available but not necessarily as a full on-pack ingredients label). The purpose is that a customer, especially an allergic one, can pick up the packaged PPDS item and see, on its label, the full ingredients and emphasised allergens, and make a safe, informed choice. So label PPDS food with the name and a full ingredients list with the 14 allergens emphasised. Follow the current FSA/GOV.UK guidance on how to label PPDS food. This is general information.
Natasha's Law - the PPDS allergen-labelling requirement - came into force on 1 October 2021 in England, Wales and Northern Ireland. Since that date, it has been a legal requirement for food prepacked for direct sale (PPDS) to be labelled with the name of the food and a full ingredients list with the 14 regulated allergens emphasised within it. So the duty has applied since October 2021, and food businesses making and packing PPDS food on site have needed to comply since then - identifying their PPDS food and labelling it correctly. The law was introduced following the death of Natasha Ednan-Laperouse from an allergic reaction to a PPDS baguette that did not carry allergen information, to close the gap in allergen labelling for such food. So it has been in force since 1 October 2021, and businesses should already be complying; any business making PPDS food that is not labelling it with the name and full emphasised-allergen ingredients list needs to bring its labelling into compliance. This is general information, not legal advice; follow the current FSA/GOV.UK guidance, which sets out the requirements and how to comply.
By knowing the full ingredients and allergens of each product accurately, and basing the labels on that. To label a PPDS item correctly, the business must know the full ingredients of the product (every ingredient, to list them all) and which of the 14 allergens it contains (to emphasise them correctly) - so it needs accurate ingredient and allergen information for each product. This requires good practice behind the labelling: knowing the recipes and ingredients of each product, knowing the allergens in each ingredient (including in compound ingredients and any supplier ingredients used), and keeping this information accurate and up to date (so the labels are correct, and updated if a recipe or ingredient changes). Getting this right matters greatly because the labelling is for allergic consumers' safety - an inaccurate label (missing or wrong ingredient or allergen) could be dangerous and is a legal failing. So the labelling must be accurate, based on genuine knowledge of the food, which means having the systems to know your products' ingredients and allergens and produce correct, up-to-date labels - part of good allergen management. So identify your PPDS food, know its ingredients and allergens accurately, and label each item correctly and keep it up to date. This is general information; follow the current FSA/GOV.UK guidance.
PPDS labelling is one part of the wider allergen management a food business must do, which also includes controlling allergen cross-contamination - and that control depends partly on cleaning. Allergen management overall involves knowing and managing the allergens in your food, informing customers (through PPDS labelling for PPDS food, and allergen information for non-prepacked food), and controlling allergen cross-contamination in the kitchen (so allergens do not unintentionally get into foods where they should not be). PPDS labelling addresses the informing part for PPDS food (the label), while cross-contamination control addresses keeping allergens out of the wrong foods - and that control depends partly on cleaning (clean surfaces, equipment and utensils, so allergen residues do not transfer between foods). So while PPDS labelling is about the label, the wider allergen management it belongs to also involves cleaning to control cross-contamination. So comply with the PPDS labelling duties (the label) as part of good overall allergen management, which also includes controlling allergen cross-contamination, supported by keeping the kitchen and equipment clean. This is where cleaning connects to allergen management: clean surfaces and equipment support cross-contamination control, complementing the labelling duties. This is general information; follow the current FSA/GOV.UK guidance on PPDS labelling and allergen management.
PPDS labelling is one part of allergen management; controlling cross-contamination is another, and it depends partly on cleaning - clean surfaces and equipment so residues do not transfer. Our kitchen deep cleaning keeps the kitchen clean, supporting allergen control alongside the labelling duties. Ask us about keeping your kitchen clean.
